Message-ID: <23447289.1075858656994.JavaMail.evans@thyme>
Date: Thu, 30 Aug 2001 15:35:34 -0700 (PDT)
From: stacey.bolton@enron.com
To: richard.ring@enron.com
Subject: MI language
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Let me know what you think:
=20
Enron would like to compliment staff on their recommendations for the discl=
osure label calculations and offer one suggestion that would accommodate th=
e purchase of clean, renewable resources.  As noted in our prior comment, w=
e would like to reiterate the need for a methodology that recognized attrib=
ute contracts.  It is a growing practice to contract for the renewable or c=
lean attributes of energy that have been generated onto the grid without pu=
rchasing the actual commodity power.  These attributes are typically referr=
ed to as certificates, "green tags" or "renewable energy credits".  All of =
these terms refer to the environmental benefits of clean power that have be=
en generated onto the grid and may be traded, bought and sold separately fr=
om the underlying power commodity.  The ability to separate the attributes =
from the underlying power facilitates the ability for suppliers to offer cl=
ean renewable power in regions where it might not be conducive to site thes=
e resources.   The supplier can then pair the attributes with system power =
at the point of sale to Michigan customers.
=20
This methodology greatly decreases the administrative reporting burden for =
suppliers and also provides a cost-effective form of verification for Commi=
ssion staff.  Our specific recommendations for accounting for certificates =
are as follows.=20
1. Allow suppliers to account for attribute purchases on their fuel labels =
by providing proper substantiation that the supplier owns the attributes.  =
Substantiation can be in the form of verification from an independent syste=
m operator of an attribute registry (e.g. Automated Power Exchange operatin=
g in California and the Midwest and recently awarded the contract for NePoo=
l to build their certificate based system; ERCOT) that the supplier has pur=
chased the certificate and retired it on the behalf of the customer; a bila=
teral contract showing that the attributes are owned by the supplier, or an=
y other method deemed appropriate by the Commission.
2. Suppliers can use the generation data from certificates that have been g=
enerated by independent certificate system administrators or generators to =
calculate the fuel type and emissions.   The certificate purchases would be=
 weighed with other bilateral contracts and spot market purchases for purpo=
ses of calculating the label.
3.  In the event that the emissions data are not provided by the generator,=
 suppliers will be able to use the most recent E-grid data to calculate the=
 emissions.
=20
There are several examples from other State Commissions for accounting for =
certificates purchases.  The following link shows the methodology that the =
Texas Public Utility Staff wrote for calculating labels with certificate pu=
rchases.  <http://www.puc.state.tx.us/rules/rulemake/22816/22816.cfm>
=20
This modification to the label calculation will allow suppliers who are pur=
chasing affordable clean to be delivered to the grid on behalf of their cus=
tomers through certificate contracts to depict this on their fuel content l=
abel.  We appreciate your review of our comments.
=20
Stacey Bolton
Environmental Strategies
Enron Corp
713-853-9916 direct=20
713-303-2632 cell=20
sbolton@enron.com <mailto:sbolton@enron.com>
=20
